The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...
Counter Tax Litigators LLP proudly announces the International Tax Review has named Peter Aprile, Senior Counsel and Practice Group Leader, a finalist for the Tax Disputes & Litigation Practice Leader...
Counter Tax Litigators LLP proudly announces its recognition by the International Tax Review (ITR) in the prestigious ITR World Tax 2025 Rankings for its expertise in Tax Controversy (Canada).
Counter Tax Litigators LLP proudly announces that it has been shortlisted for the prestigious Tax Innovator of the Year award by International Tax Review. This esteemed recognition celebrates the firm...
Recent Supreme Court of Canada (SCC) rulings provide critical guidance on tax dispute jurisdiction, shaping how tax reassessments and ministerial decisions should be challenged.
Counter Tax Litigators LLP proudly announces the launch of its latest impact initiative, CountHerIn: Women in Tax Network.
Cryptocurrencies have redefined wealth creation but also bring unprecedented challenges for tax planning and compliance. As cryptocurrency values soar and governments worldwide heighten scrutiny, Cana...
Executive Summary: The Tax Court drew a hard line: choosing non-CCPC status before a sale is not abuse, at least until Parliament closed the door in 2022.
Key Takeaways Under Income Tax Act s.165(1.11), a large corporation must reasonably describe each issue and the relief sought in its initial Notice of Objection.
Key Takeaways Economic substance framed: The FCA upheld a constrained structure because it was positioned around real economic gains, not technical form. Whole-plan control: GAAR outcomes often hinge ...